Fees and Compensation — Form ADV Part 2A (3/18/2021)
[Brochure]
Item 5: Fees and Compensation
Strategies employed by PTLLC require highly frequent trading, resulting in substantial
brokerage commissions and other transaction fees and expenses. In these instances, the
brokerage and commission expenses of certain Clients may exceed those of other private
funds of comparable asset size, though PTLLC believes that the brokerage and commission
expenses are necessary in order to implement the PTLLC investment strategy.
If a Client and one or more other Client, or other Clients of PTLLC may be responsible for
some or all of a particular cost, PTLLC may allocate the cost among all those entities, Clients,
and PTLLC in its discretion in a fair and equitable manner. Any expense common to any
other Client or other Clients managed by PTLLC or its affiliates generally will be paid pro rata
by such entities based on the eligible Client’s assets under management (or in any other
manner deemed fair and equitable by PTLLC, in PTLLC’s sole discretion). Expenses allocated
to Clients may be negotiated individually. At its discretion or pursuant to the terms of an
investment advisory agreement or Client Governing Documents, PTLLC may pay expenses
that would otherwise be allocated to a Client. Clients that do not pay a portion of these
expenses may benefit from services paid for by other Clients or PTLLC.
PTLLC has a conflict of interest in determining the rates or fees paid by a Client to PTLLC,
PTLLC affiliates and any operating expenses provided by PTLLC or an affiliate that are paid
by Clients.
Withdrawals of capital by a Fund Investor from a private fund client are typically subject to a
lock- up period, compulsory notice period, and could be subject to a gate or suspension as
described in the relevant Client Governing Documents. PTLLC or an affiliate maintain
discretion to waive or modify the notice period.
PTLLC may, as agreed to and as disclosed to certain clients, charge fees that vary from the
fees described above. Such fees will be set forth in the applicable Client Governing
Documents. Clients and Fund Investors are encouraged to review the applicable Client
Governing Documents for a detailed description of fees and expenses applicable to the
specific Client.
Part 2A of Form ADV: Polaris Technologies, LLC Brochure
Account Minimums and Types of Clients — Form ADV Part 2A (3/18/2021)
[Brochure]
Item 7: Types of Clients
PTLLC’s only clients are the Private Funds.
Part 2A of Form ADV: Polaris Technologies, LLC Brochure